Federal Tax Procedure Book (2023.2 Editions) (1/1/24)

2023.2 Editions of the book:

I previously posted the 2023 versions of the Student and Practitioners 2023 Edition on SSRN in August 2023. I posted update versions, called 2023.2 editions of each, in early January 2023. As I understand the process on SSRN, SSRN has to approve the new versions. So be sure and get the 2023.2 version. See below under the caption REASONS FOR NEW 2023 VERSIONS JANUARY 2024.
  • Federal Tax Procedure (2023 Student Ed.), SSRN here.  This edition has no footnotes and is designed for the federal tax procedure student.  I present the core tax procedure information that I feel appropriate for students without the level of detail and distraction offered in footnotes (which are in the Practitioner Edition).  Key Code and case citations that the student should know are in the body of the text.  
  • Federal Tax Procedure (2023 Practitioner Ed.), SSRN here.  This edition has the same text as the Student Edition but also offers footnotes that support or discuss points in the text.  This edition is more suited to practitioners who may need that level of detail.
I provide resource links in the Appendix to each Edition and in the right-hand column of this Blog.  

PERMISSION TO USE.  All readers are given permission to use the books.  The books are copyrighted, so appropriate credit to the book is appreciated when the contents are used in other publications.  Any use (even beyond "fair use" in copyright sense (see here)) is permitted, provided only the proper credit to my publication is given prominently with such use.

UPDATES AND CORRECTIONS. I may offer updates, corrections, changes, etc. (collectively "Updates") through blog entries.  Throughout the year, I make many changes to the working draft of the next annual editions.  Some of the changes are significant, representing important developments or corrections to errors in the 2023 Editions.  For those significant changes, I will post them as blog entries stating the change and referencing the page numbers affected in each Edition.  Readers can access updates in either of two ways:
  • A blog page (right column) titled Federal Tax Procedure Book 2023 Editions Updates, here.   This lists the significant updates and changes to the 2023 Editions by chapter, with appropriate links.
  • By blog keyword titled "FTPB 2023 Updates," [Link to come]. The search results are first generated by relevance, but by clicking a link at the top, you can see the entries in reverse chronological order.
  • Procedurally Taxing Blog. This blog is an outstanding source.  It formerly was free but is now a subscription service by Tax Notes / Tax Analysts.
  • Michael Saltzman and Leslie Book, IRS Practice and Procedure (Thomsen Reuters 2015), here
I highly recommend the most detailed and authoritative discussion of Federal Tax procedure, (Disclosure: I am the principal draftsman of Chapter 12 of that publication, titled Criminal Penalties and the Investigation Function.)  That treatise is cited frequently by the courts, from the Supreme Court on down.  For those wanting definitive research, that treatise should be consulted.  To give you some idea of the depth of the coverage, chapter 12 on Criminal Penalties and the Investigative Function was 311 pages (with footnotes) in the original pdf copy when published in 2015.  By contrast, in my Federal Tax Procedure Book Practitioner 2023.2 Edition (with footnotes), I cover that topic in part of Chapter 6, titled Penalties, in 42 pages.  Keep in mind that the principal target for my Federal Tax Procedure Book is the student but provide footnotes in the Practitioner edition to offer more detail but not in any way to compete with the discussion in the Saltzman & Book treatise.
  • Forms.  IRS Forms, Instructions & Publications may be obtained from the IRS website of the same name, here.  In 2017, I provided a set of forms in pdf format, here, but some of these forms have been revised since 2017.  So, be sure and check for any updates on the IRS website.
  • Materials.  I offer here in pdf format a collection of materials (key cases, select John Doe Summons documents and articles) that I asked the students to read and be prepared to discuss in class, Caveat:  I have not updated these materials set recently. 
  • Problem Set.  I do not have a problem set for this book.  I offer copies of some of my examinations from my most recent years of teaching at the University of Houston Law School (ending in Fall 2015).  These questions may span different Chapters of the books, so they may not be suited for chapter-by-chapter discussion of problems.  Professors might be used to create a chapter-by-chapter problem set.  Or Students may use the examinations to review, either for an examination or just general review.  Many of the examination questions are based (at least conceptually) on examples given in the text of the two editions.
    • 2015 Examination, here.
    • 2014 Examination, here.
    • 2013 Examination, here.
    • 2012 Examination, here.
    • 2011 Examination, here.
  • I encourage and value comments (including, most importantly, items that should be corrected, deleted, or included).  Comments (including anonymous) may be offered (on this blog page (at bottom) or (ii) emailed to me, jack@tjtaxlaw.com.  I will use these comments to make the next edition better and, if appropriate, make updates through the update techniques described above.
  • If you are using either Edition for teaching, I would appreciate your advising me.  It is always good to know which teachers and classes are using the book. 
  • I welcome examples of problems that professors use to help their students better understand tax procedure concepts.  Perhaps with enough suggestions, I can prepare a set of problems with answers for the book.  If I use problems (or reasonable variants) submitted to me, I will give appropriate credit to the professor developing the problems.
    EARLIER EDITIONS OF THE FEDERAL TAX PROCEDURE BOOK.  These may be downloaded from my SSRN author page, here.

    • The initial  2023 editions used larger fonts (Century 14 in text and 12 in footnotes), thus substantially increasing the page length of the book. Reader feedback was not positive, so I decided to return to the original font and size versions (Times New Roman with font size 12 and, in the Practitioner Edition, footnote font size 10). 
    • The pdf versions of the original versions did not carry forward some special attributes such as italics and bold-face that were in the original word processor documents. That has been corrected in the 2023.2 versions.
    • Since I update the working draft for the next editions throughout the year, I have included redlines to indicate update material in the 2023.2 versions. I have corrected without redlining more minor errors, such as typos. And, of course, as often occurs, I have not picked up all text needing some correction. (I find it very hard to proofread my own writing; so I would appreciate hearing from others as to improvements they think I can make.)

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